Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page 21
... payment of accrued deductions until near the end of the partnership's taxable year . [ H. Conf . Rept . 98-861 , at 855 ( 1984 ) , 1984-3 C.B. ( Vol . 2 ) 1 , 109 ; emphasis added . ] The origins of section 706 ( d ) ( 1 ) reveal that ...
... payment of accrued deductions until near the end of the partnership's taxable year . [ H. Conf . Rept . 98-861 , at 855 ( 1984 ) , 1984-3 C.B. ( Vol . 2 ) 1 , 109 ; emphasis added . ] The origins of section 706 ( d ) ( 1 ) reveal that ...
Page 27
... payments from foreign parents to domestic subsidiaries " and contains no text . The Secretary explicitly " [ RESERVED ] " the rules under that provision during the years in issue . In 1992 the Secretary promulgated new final regulations ...
... payments from foreign parents to domestic subsidiaries " and contains no text . The Secretary explicitly " [ RESERVED ] " the rules under that provision during the years in issue . In 1992 the Secretary promulgated new final regulations ...
Page 28
... payments from foreign non - controlled payors . See TD 8412 ( 1992-1 C.B. 271 , 273 ) . Treasury and the IRS continue to ... payment constitutes income from the active conduct of a trade or business of the recipient . [ Id . ] The ...
... payments from foreign non - controlled payors . See TD 8412 ( 1992-1 C.B. 271 , 273 ) . Treasury and the IRS continue to ... payment constitutes income from the active conduct of a trade or business of the recipient . [ Id . ] The ...
Page 63
... Payments made by withhold- ing from petitioner's wages are deemed paid on the 15th day of the 4th month following the ... payment obligations under these mortgages , Ps and FmHA negotiated an alternative arrangement . Pursuant thereto ...
... Payments made by withhold- ing from petitioner's wages are deemed paid on the 15th day of the 4th month following the ... payment obligations under these mortgages , Ps and FmHA negotiated an alternative arrangement . Pursuant thereto ...
Page 65
... payment obligations on these mortgages , petitioners contacted Richard A. Guenther , County Supervisor and Agriculture Credit Man- ager of the Dane County office of the Farm Service Agency , to explain their situation and to consider ...
... payment obligations on these mortgages , petitioners contacted Richard A. Guenther , County Supervisor and Agriculture Credit Man- ager of the Dane County office of the Farm Service Agency , to explain their situation and to consider ...
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9th Cir ACC's acquired acquisition affd agreement Alcon P.R. allocation amount annuity applicable Avitene AVLP Bank bankruptcy bankruptcy estate benefits capital asset capital expenditures claim clubhouse Commissioner Congress corporation costs Court of Appeals decedent deduction election employees entrance fee escrow exit fee expenses fact FDIC Federal income tax filed gross income Humacao Idaho Power Co Income Tax Regs income tax return incurred INDOPCO information return insolvent installment contracts Insurance Fund Internal Revenue Code Internal Revenue Service issue Judge Drennen Kirby Lumber Co limited partnership interest loans manufacturing MedChem P.R. MedChem U.S.A. ment Metrobank notice of deficiency overhead paid parties partner payment percent period peti petition petitioner's petitioners provides Puerto Rico purchase purposes relief reported respondent's Rule SAIF salaries sioner Stat stipulated supra T.C. Memo Tax Court taxable taxpayer tion trade or business transaction transferred Vetrano Woburn